We consider ensuring the right to the protection of personal data as a fundamental Anélle Maison commitment, therefore we will dedicate all the necessary resources and efforts to process your data in full accordance with Regulation (EU) 2016/679 ("General Data Protection Regulation" or "GDPR"), as well as with any other legislation applicable on the territory of Romania and EU. Since one of the essential principles of this legal framework is transparency, we have prepared this document through which we want to inform you about how we collect, use, transfer and protect your personal data when you interact with us in relation to products and services ours, including through our website or through the applications available on the mobile phone.

We reserve the right to periodically update and modify this Privacy Policy, to reflect any changes in the way we process your personal data or any changes in legal requirements. In case of any such modification, we will display the modified version of the Privacy Policy on our website, which is why we ask you to periodically check the content of this Privacy Policy.

Who we are and how you can contact us

Anélle Maison is the commercial name of ELDEA SHOP S.R.L., a legal entity of Romanian nationality, with its registered office in Voluntari, Jud. Ilfov, Bd. Pipera, no. 1D-4, floor 4, apartment 47, with order number in the Trade Register J23/2655/2024, unique fiscal registration code 49898940 (hereinafter "Anélle Maison" or "us"). In the sense of the data protection legislation, we are the operator when we process your personal data.

Since we are always open to your opinions, as well as to provide you with any additional information you may need regarding the processing of your data, we encourage you to contact the Anélle Maison Data Protection Officer at contact@anellemaison.com or by post or courier to the address Voluntari street, Jud. Ilfov, Bd. Pipera, no. 1D-4, floor 4, app. 47 – with the note: Attention Anélle Maison Data Protection Officer.

What are the purposes and grounds of the processing

We will use your personal data for the following purposes:

1. For the provision of Anélle Maison services for your benefit

This general purpose may include, as the case may be, the following:

• Account creation and administration within the Anélle Maison platform;
• Order processing, including receiving, validating, sending and invoicing them;
• Solving cancellations or problems of any nature related to an order, goods or services purchased;
• Returning products according to legal provisions;
• Reimbursement of the counter value of the products according to the legal provisions;
• Providing support services, including providing answers to your questions regarding your orders or Anélle Maison goods and services. • Using the "My Preferences" service

The processing of your data for these purposes is in most cases necessary for the conclusion and execution of a contract between Anélle Maison and you. Also, certain processing subsumed for these purposes is required by applicable legislation, including fiscal and accounting legislation.

2. To improve our services

We always want to offer you the best online shopping experience. For this, we can collect and use certain information about your behavior as Buyers, we can invite you to complete satisfaction questionnaires following the completion of an order or we can conduct, directly or with the help of partners, studies and market research.

We base these activities on our legitimate interest to carry out commercial activities, always taking care that your fundamental rights and freedoms are not affected.

3. For marketing

We want to keep you informed about the best offers for the products/services that interest you. In this sense, we can send you, for Anélle Maison, any type of message (such as: e-mail/SMS/telephone/mobile push/webpush/etc.) containing general and thematic information, information about similar products or complementary to those you have purchased, information on offers or promotions, information on products added to the "Account/My Basket" section or the "Account/Favorites" section or you have shown interest in purchasing them, as well as other communications commercial purposes such as market research and opinion polls, and we may display personalized recommendations on the website and in the smartphone application. In order to provide you with information of interest to you, we may use certain data regarding your buyer behavior (e.g. products viewed / added to wishlist / purchased) to create a profile for you. We always make sure that these processes are carried out with respect for your rights and freedoms, and that the decisions taken based on them do not have legal effects on you and do not similarly affect you to a significant extent.

In most cases, we base our marketing communications on your prior consent. You can change your mind and withdraw your consent at any time, by:

• Changing the settings in the customer account in the "Preferences" section;
• Accessing the unsubscribe link displayed in the messages you receive from us;
• or by contacting Anélle Maison using the contact details described above.

In certain situations, we may base our marketing activities on our legitimate interest to promote and develop our commercial activity. In any situation where we use information about you for a legitimate interest of ours, we take care and take all the necessary measures so that your fundamental rights and freedoms are not affected. However, you can request us at any time, through the means described above, to stop the processing of your personal data for marketing purposes, and we will comply with your request.

4. To defend our legitimate interests

There may be situations in which we will use or transmit information to protect our rights and commercial activity. These may include:

• Measures to protect the website and users of the Anélle Maison platform against cyber-attacks:
• Measures to prevent and detect fraud attempts, including the transmission of information to the competent public authorities;
• Measures to manage various other risks.

The general basis of these types of processing is our legitimate interest to defend our commercial activity, it being understood that we ensure that all the measures we take guarantee a balance between our interests and your fundamental rights and freedoms.

Also, in certain cases we base our processing on legal provisions such as the obligation to ensure the protection of goods and valuables provided by the applicable legislation in this matter.

How long we keep your personal data

As a general rule, we will store your personal data as long as you have an account on the Anélle Maison platform. You can ask us at any time to delete certain information or to close the account, and we will comply with these requests, subject to the preservation of certain information including after the closure of the account, in situations where the applicable legislation or our legitimate interests require it.

To whom we transmit your personal data

As the case may be, we may transmit or provide access to certain personal data of yours to the following categories of recipients:

• companies within the same group of companies as Anélle Maison;
• courier service providers;
• providers of payment/banking services;
• marketing / telemarketing service providers;
• market research service providers;
• insurance companies;
• IT service providers;
• other companies with which we can develop joint programs for offering our goods and services on the market.

If we have a legal obligation, or if it is necessary to defend a legitimate interest, we can also disclose certain personal data to public authorities.

We ensure that access to your data by third parties under private law is carried out in accordance with the legal provisions regarding data protection and information confidentiality, based on contracts concluded with them.

In which countries do we transfer your personal data?

As a general rule, your personal data is stored and processed within the European Union and the European Economic Area (EEA).

In the event that your personal data will be transferred outside the European Union or the EEA, the transfer will be carried out (a) on the basis of a decision of the European Commission by which it decides that the third country in question provides an adequate level of protection, ( b) based on mandatory corporate rules or (c) based on standard contractual clauses adopted by the European Commission. Additionally, in the event that we identify that one of these measures is not sufficient to ensure an adequate level of protection, on a case-by-case basis, we will adopt additional technical and/or organizational security measures in accordance with the recommendations of the European Commission.

How we protect the security of your personal data

We are committed to ensuring the security of personal data by implementing appropriate technical and organizational measures, according to industry standards.

The transmission of your personal data is done using the latest encryption algorithms and we store them on secure servers, ensuring data redundancy at the same time.

To make payments, we use the services of the PayU payment processor. Any payment information is encrypted, using HTTPS technology with TSL 1.2 encryption.

Despite the measures taken to protect your personal data, we draw your attention to the fact that the transmission of information via the Internet, in general, or through other public networks, is not completely secure, as there is a risk that the data will be seen and used by third parties unauthorized. We cannot be responsible for such vulnerabilities of systems that are not under our control.

What rights do you have?

The general data protection regulation grants you a number of rights in relation to your personal data. You can request access to your data, the correction of any mistakes in our files and/or you can object to the processing of your personal data. You can also exercise your right to complain to the competent supervisory authority or to go to court. As the case may be, you can also benefit from the right to request the deletion of your personal data, the right to restrict the processing of your data and the right to data portability.

More information about each of these rights can be obtained by consulting the table presented below.

To be able to exercise your rights, you can contact us using the contact details set out above. Please keep the following aspects in mind if you wish to exercise these rights:

Identity

We take seriously the confidentiality of all Registrations that contain personal data. For this reason, please send us your requests regarding such Registrations using the email address associated with the Anélle Maison account. Otherwise, we reserve the right to verify your identity by requesting additional information aimed at confirming your identity.

Fees

We will not charge a fee to exercise any right regarding your personal data, unless your request for access to information is unfounded, repetitive or excessive, in which case we will charge a reasonable amount In such circumstances. We will inform you about any fees applied before resolving your request.

Response time.

We aim to respond to any valid requests within a maximum of one month, unless this is particularly complicated or if you have made several requests, in which case we will respond within a maximum of two months. We will let you know if we need more than a month. We might ask you if you can tell us exactly what you want to receive or what you are worried about. This will help us act faster and shorten the response time to your request.

Third party rights

We must not comply with a request in the event that it would negatively affect the rights and freedoms of other persons concerned.

Entitled rights access

You can ask us:

• to confirm whether we are processing your personal data;
• to provide you with a copy of this data;
• to provide you with other information about your personal data, such as the data we have, what we use it for, to whom we disclose it, if we transfer it abroad and how we protect it, how long we keep it, what rights you have, how you can make a complaint, where we obtained your data, to the extent that the information has not already been provided to you through this information.

Correction

You can ask us to rectify or complete your inaccurate or incomplete personal data.

It is possible for us to try to check the accuracy of the data before rectifying them.

Data deletion

You can ask us to delete your personal data, but only if:

• they are no longer necessary for the purposes for which they were collected; or
• you have withdrawn your consent (if data processing is based on consent); or
• exercise a legal right to object; or
• they were processed illegally; or
• we have a legal obligation in this regard.

We are not obliged to comply with your request to delete your personal data If the processing of your personal data is necessary:

• to comply with a legal obligation; or
• for ascertaining, exercising or defending a right in court.

There are certain other circumstances in which we are not obliged to comply with your data deletion request, although these two are the most likely circumstances in which we may refuse your request.

Keep in mind that, before exercising this right, you download from your Anélle Maison account and save all the documents related to the orders made by Anélle Maison, regardless of whether the billing was done to you or to another natural or legal person (such as be: invoices, warranty certificates). If you do not take this step before exercising your right of deletion, you will lose all these documents and Anélle Maison will be unable to make them available to you, as the case may be, because the process of deleting the data, respectively the account Anélle Maison, with all the data and documents related to it, is an irreversible process.

Restriction of data processing

You can ask us to restrict the processing of personal data, but only if:

• their accuracy is challenged (see the rectification section), to allow us to verify their accuracy; or
• the processing is illegal, but you do not want the data to be deleted; or
• they are no longer necessary for the purposes for which they were collected, but you need them to establish, exercise or defend a right in court; or
• you have exercised your right to object, and the verification of whether our rights prevail is ongoing.

We may continue to use your personal data following a restriction request, if:

• we have your consent; or
• to establish, exercise or ensure the defense of a right in court; or
• to protect the rights of Anélle Maison or another natural or legal person.

Data portability

You can ask us to provide you with your personal data in a structured, currently used and machine-readable format, or you can request that it be "ported" directly to another data operator, but in each case only if:

• the processing is based on your consent or on the conclusion or execution of a contract with you; and
• processing is done by automatic means.

The opposition

You can object at any time, for reasons related to your particular situation, to the processing of your personal data based on our legitimate interest, if you consider that your fundamental rights and freedoms prevail over this interest.

Also, you can object at any time to the processing of your data for direct marketing purposes (including the creation of profiles), without invoking any reason, in which case we will stop this processing as soon as possible.

Automated decision making

You can ask not to be the subject of a decision based solely on automated processing, but only when that decision:

• produces legal effects regarding you; or
• affects you in another similar way and to a significant extent.

This right does not apply if the decision reached following automatic decision-making:

• it is necessary for us to conclude or carry out a contract with you;
• is authorized by law and there are adequate guarantees for your rights and freedoms; or
• is based on your explicit consent.

Claims

You have the right to file a complaint with the supervisory authority regarding the processing of your personal data. In Romania, the contact details of the supervisory authority for data protection are as follows:

National Supervisory Authority of Personal Data Processing

G-ral Blvd. Gheorghe Magheru no. 28-30, Sector 1, postal code 010336, Bucharest, Romania
Telephone: +40.318.059.211 or +40.318.059.212;
Email: anspdcp@dataprotection.ro

Without affecting your right to contact the supervisory authority at any time, please contact us in advance, and we promise that we will make every effort to resolve any problem amicably.

We remind you that you can contact the Anélle Maison Data Protection Officer at any time by sending your request through any of the following methods:

¬ by e-mail to the address: contact@anellemaison.com or
¬ by post or courier to the address: Voluntari, Jud. Ilfov, Bd. Pipera, no. 1D-4, floor 4, apartment 47 – with the mention to the attention of the Anélle Maison Data Protection Officer.